Taxation of immovable property allows the state where the property is situated to tax income from its use and exploitation. Income derived by a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in the State where the property is located. This rule applies to income from direct use, letting or other forms of exploitation, and extends to enterprise income and income used for independent personal services. Immovable property is defined by the law of the State where the property is situated and includes accessories, agricultural livestock and equipment, rights treated as landed property, usufruct, and rights to payments for working or rights to work mineral deposits and other natural resources; ships, boats and aircraft are excluded.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of immovable property allows the state where the property is situated to tax income from its use and exploitation.
Income derived by a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in the State where the property is located. This rule applies to income from direct use, letting or other forms of exploitation, and extends to enterprise income and income used for independent personal services. Immovable property is defined by the law of the State where the property is situated and includes accessories, agricultural livestock and equipment, rights treated as landed property, usufruct, and rights to payments for working or rights to work mineral deposits and other natural resources; ships, boats and aircraft are excluded.
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